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Compliance Bricks and Mortar for January 16

Posted on January 16, 2015 by Doug Cornelius
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black and white bricks

These are some of the compliance-related stories that recently caught my attention.

RBS Loses Senior Compliance Staff, Some Poached by HSBC by Margot Patrick And Rachel Louise Ensign in the Wall Street Journal

The departures come as RBS, 80%-owned by the British government, faces a potential multibillion-dollar settlement with the Federal Housing Finance Agency over mortgage-backed debt it sold to Freddie Mac and Fannie Mae before the 2008 financial crisis.

Say Hello to the SEC’s Digital Currency Working Group (.pdf) by Marco Santori and Jeffrey Jacobi from Pillsbury

Now that enforcement agencies have determined that digital currencies are more than a passing fad, they are establishing more permanent efforts focused on the novel legal issues digital currencies present. The SEC’s formation of its multi-office Digital Currency Working Group may foreshadow an increase in the agency’s exercise of regulatory authority over entities offering interests in Bitcoin and other digital currencies

Justice Department Files First FCPA Case of 2015, Reminds Lawyers to Watch Out by David Smyth in Cady Bar The Door

Last week, the Justice Department filed the first FCPA case of 2015 when it indicted Dmitrij Harder, the former owner and president the Chestnut Consulting Group in Huntingdon Valley, Pa…

The case is interesting to me for at least four reasons. First, the European Bank for Reconstruction and Development is based in the United Kingdom, not a high-risk country for corruption issues. Second, the case doesn’t involve third party sales agents, as so many FCPA cases tend to do in one way or another. Instead, if the indictment is to be believed, here we have a company president’s single-minded determination to pay some bribes to win business, one way or the other. Third, the case invokes the “public international organization” facet of the foreign official element to establish jurisdiction over the conduct at issue. Doesn’t happen very often!

SEC Enforcement – An Analysis of Key Developments in 2014 by Bruce Carton in Compliance Week

In a webcast I moderated yesterday, a panel consisting of four former senior SEC enforcement attorneys and accountants–including former SEC Enforcement Director Bill McLucas of law firm WilmerHale–analyzed the most important developments in SEC enforcement from 2014, and looked ahead at what they expect in 2015.

Black & White Bricks is by Mike

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